pretrial-statement

name	pretrial-statement
title	Pre-Trial Statement / Report
description	Drafts U.S. commercial litigation pre-trial statements and joint pretrial reports presenting stipulated facts, contested issues, witness/exhibit lists, and trial management items. Trigger when the user needs a pre-trial statement, joint pretrial report/order, trial readiness filing, or witness/exhibit compilation under local rules.
author	CaseMark
author_url	https://github.com/CaseMark/skills/tree/main/skills/legal/pretrial-statement
license	Apache-2.0
version	0.1.0
execution_mode	open
jurisdiction	us
practice	litigation
language	en
tags	["drafting","pleading"]

Pre-Trial Statement / Report

Draft a court-compliant pre-trial statement that narrows issues and provides the trial roadmap.

Quick Start

Gather before drafting:

1. Local rules / judge order — controls required sections and format.
2. Case posture — claims, defenses, key rulings.
3. Stipulated facts — agreed wording from opposing counsel (if joint).
4. Contested issues — law and fact, aligned to trial themes.
5. Witness disclosures and expert reports.
6. Exhibit inventory — Bates numbers, exhibit IDs.
7. Trial management inputs — length, jury/bench, motions in limine status.

Document Structure

1. Caption + Title
2. Introductory paragraph (filing type, governing order)
3. Stipulated Facts
4. Contested Issues of Law
5. Contested Issues of Fact
6. Witness List
7. Exhibit List
8. Procedural / Trial Management Matters
9. Signature block(s) per local rule

Section Details

Stipulated Facts

One fact per number; use verbatim agreed wording. Non-argumentative only.

No.	Stipulated Fact (verbatim)	Source / Record Cite	Notes

Contested Issues of Law

Frame each as a discrete question the court must decide.

No.	Legal Issue (question)	Authority	Impact on Trial

Phrasing patterns:

• "Whether [legal standard] applies to [claim/defense] where [key fact]…"
• "Whether [doctrine] bars [claim] given [contract/statute]…"

Contested Issues of Fact

State neutrally at meaningful granularity.

No.	Factual Issue (neutral)	Key Evidence Sources	Notes

Phrasing patterns:

• "Whether [party] represented [fact] on [date]."
• "Whether [event] caused [harm/damages]."

Witness List

Only properly disclosed witnesses; flag proposed additions.

Order	Witness Name	Type (Fact/Expert)